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Free Trials

UB Greensfelder LLP

FTC Implements New Rule Regulating Subscription-Based Services, Free Trial Offers, and Other Automatic Renewal Sales Systems

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The Federal Trade Commission (FTC) introduced its updated Negative Option Rule on October 16, 2024 (the “New Rule”). The New Rule targets deceptive practices associated with subscription-based services through which companies...more

Lerman Senter PLLC

What the FTC's Click to Cancel Rule Means for Subscription Services

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Subscription-based services are a lynchpin of the services industry and the current focus of the Federal Trade Commission’s (FTC) new “click to cancel” rule. Responding to customer complaints focusing on the difficulty of...more

Hinch Newman LLP

California Expands “Dark Pattern” Automatic Renewal Legislation

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On October 16, 2024, the Federal Trade Commission announced the final FTC “Click-to-Cancel” Rule pertaining to recurring subscriptions and memberships. The Federal Trade Commission is not the only regulatory agency that...more

Stradling Yocca Carlson & Rauth

Beware of the FTC’s Proposed Changes to The Negative Option Rule… There is a Potential Trojan Horse

Key Takeaways - In its current form, the Negative Option Rule covers only a narrow category of negative option marketing – prenotification negative option plans. The FTC’s proposed Rule seeks to synthesize all of the...more

Troutman Pepper Locke

Autorenewals - The Crypto Exchange Podcast

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Most consumers have signed up for subscriptions, automatic deliveries, or free trials that convert into a paid subscription. In this episode of The Crypto Exchange, Carlin McCrory welcomes colleagues Mark Furletti and Jill...more

Troutman Pepper Locke

CFPB Files Action Against Online Event Registration Company for Alleged “Digital Dark Patterns” and “Online Trickery”

Troutman Pepper Locke on

On October 18, the Consumer Financial Protection Bureau (CFPB) filed a complaint in a Texas federal court against Active Network LLC (Active) for allegedly tricking people, when trying to sign up for a fundraising race or...more

Hinch Newman LLP

eCommerce Attorney Tips Regarding Recent Automatic Renewal Law Developments

Hinch Newman LLP on

For years, the Federal Trade Commission has aggressively enforced the Restore Online Shoppers’ Confidence Act against digital marketers that offer Internet-based automatic renewals and subscriptions. In short, ROSCA requires...more

Hudson Cook, LLP

Let 'Em Out! ROSCA and Changes to California's Auto-Renewal Law

Hudson Cook, LLP on

What's this about? Auto-renewing arrangements are more and more ubiquitous, from TV channel subscriptions to meal-kit delivery plans - and the regulators are interested. Late last year, the FTC and California took actions...more

Husch Blackwell LLP

How do the CPRA, CPA, and VCDPA treat dark patterns?

Husch Blackwell LLP on

Keypoint: The CPRA and CPA introduce the concept of dark patterns into state consumer data privacy laws although this area has come under increased attention recently with FTC enforcement actions and guidance, state attorneys...more

Ballard Spahr LLP

Subscription Service Agrees to Pay $10 Million for Automatic Renewal Law Violations

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Earlier this month, the Federal Trade Commission (FTC) announced a $10 million settlement with the online learning company ABCmouse for allegedly violating the FTC Act as well as the Restore Online Shoppers’ Confidence Act...more

ArentFox Schiff

Subscription Snack Company Hit with FTC Complaint for Misrepresenting Positive Consumer Reviews

ArentFox Schiff on

The FTC alleged that UrthBox did not disclose that some consumers received compensation, including free snack boxes, to post positive reviews. In addition, UrthBox offered “free” trial boxes during this time that resulted...more

Cozen O'Connor

Payment Processor Caught In The Web Of Allegedly Illegal “Free Trial” Scheme

Cozen O'Connor on

Consumer Protection- Payment Processor Caught in the Web of Allegedly Illegal “Free Trial” Scheme- The FTC reached a settlement with overseas payment processor SIA Transact Pro and its former Chief Executive Officer...more

Cozen O'Connor

When “Free” Trials Come With Strings Attached: Attorneys General Ask FTC To Look Into Deceptive Negative Option Marketing

Cozen O'Connor on

Consumer Protection- When “Free” Trials Come With Strings Attached: Attorneys General Ask FTC to Look Into Deceptive Negative Option Marketing- Twenty-three AGs, led by New York AG Letitia James and Pennsylvania AG Josh...more

ArentFox Schiff

Online Marketers Settle FTC Charges for Deceptive ‘Free-Trial’ Offers

ArentFox Schiff on

Operators of a negative option scam recently settled FTC charges for offering “risk-free” trials and then charging full price for the trial product and enrolling consumers in a continuous subscription without obtaining...more

Orrick, Herrington & Sutcliffe LLP

Putting Individuals In The (Urth)Box: FTC Goes After Individual Executives For Unfair And Deceptive Practices

In an increasing trend, the Federal Trade Commission (FTC) joined other federal regulators seeking to hold individuals – not just companies – liable in enforcement proceedings. The most recent target was San Francisco-based...more

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